In November two reports into food contact materials and articles (FCMs) were published in Europe that may ultimately impact the manufacturers of such products containing bamboo and melamine-formaldehyde resin:
- On November 25, 2019, the German Federal Institute of Risk Assessment (BfR) issued a risk assessment study on the use of FCM made from melamine-formaldehyde resin with and without bamboo filler additives
- On November 29, 2019, the European Food Safety Authority (EFSA) published a risk assessment related to the use of wood-based additives in plastic FCMs
‘Bambooware’ is a combination of bamboo fibers within a structural/shaping matrix made from melamine-formaldehyde resin. This material is commonly used for reusable ‘to-go’ coffee cups, tableware, etc.
While ca. 2/3 of all tested samples satisfied specific migration limits, the BfR study found this material to not necessarily be suitable for such products as both melamine and formaldehyde for the remaining 1/3 were found to migrate in high quantities from the material into the food or beverage at high temperatures.
In addition to BfR’s own study, these findings were also revealed by other German federal state market surveillance agencies. In many cases, higher quantities of formaldehyde and melamine were released from bambooware than from ‘conventional’ melamine resin items. On average, the specific migration values were found to be up to 30% higher for formaldehyde and 100% higher for melamine.
The test data included specific migration of formaldehyde from 366 cups and bowls as well as specific migration of melamine from 291 products. Compared to tolerable daily intake limits (TDIs) set by EFSA, BfR found that for about 25% of all bambooware these values were exceeded for formaldehyde by up to 30 times for adults and by up to 120 times for children. For melamine migration, adults were found to be safe. However, infants who often consume hot food/drinks from this type of tableware were found to potentially absorb TDI for melamine up to three times the TDI. The BfR concluded that there was a possible increase in health risk for consumers drinking hot liquid foods from melamine-type tableware frequently. For bambooware, a possible reason for the increase in health risk was due to high levels of formaldehyde migration from long-term daily use of such items.
Repeated use simulation tests on the same specimen, using 3% acetic acid at 70°C for 2 hours, also indicated an increasing level of melamine migration. BfR states that this indicates the material deteriorates when in contact with hot liquids and concludes that melamine-formaldehyde resin is generally not suitable for repeated use articles in contact with hot liquid foods. The BfR advises consumers that melamine-containing tableware should not be used in microwaves. As a consequence, the BfR recommends lowering the specific migration limit for formaldehyde from the present 15 mg/kg to 6 mg/kg in Commission Regulation (EU) No 10/2011.
Another risk assessment related to the use of plant-based additives in plastic food contact materials and articles (FCMs) was published on November 29, 2019 in the EFSA Journal, as Opinion 5902.
The EFSA was asked by the European Commission to
review whether the authorization of ‘wood flour and fibers, untreated’ (Entry
No 96 in Regulation (EU) No 10/2011) is still in accordance with Commission
Regulation (EC) No 1935/2004. The additive was included in the list of
additives for use in plastic FCMs based on the assumption of its inertness.
However, no toxicological evaluation supporting the inclusion of wood in the
positive list is available. Wood may contain toxic components and contaminants
and the information on migration of such substances from wood into foodstuffs
is very limited. Substance migration data from the use of wood as a plastic
additive was not available. The EFSA concluded that there is insufficient
information to support the current authorization of ‘wood flour and fibers,
untreated’ as in accordance with Regulation (EC) No 1935/2004.
The EFSA also sets out criteria for future evaluations of wood and similar materials from plant origin as plastic additives for food contact applications. The safety of migrating substances from these materials must be evaluated on a case-by-case basis due to differences in chemical composition of plant materials. The considerations are beyond species and would also include origin, processing, treatment for compatibility with the structural shaping components of plastics and assessment of low molecular weight constituents migrating into food. Comparative testing in samples manufactured with or without additives should be made on the migration of substances from the use of wood or other plant materials as additives. Toxicological data should cover the substances detected coming from such tests.
In conclusion, from these recent risk assessments, it is likely that food contact composite materials containing bamboo (or other plant) powder and melamine-formaldehyde resin will continue to face scrutiny in the EU market.
SGS Food Contact Material Services
SGS’s technical experts are highly experienced in the testing of materials and articles that will come into contact with food. Utilizing SGS’s global network of testing laboratories, they will ensure products meet the appropriate regulations for food contact materials and pave the way for compliance. They offer the full range of testing, including migration tests, along with expert advice on emerging regulations, compliance issues and documentation review. Learn more about SGS’s Food Contact Material Services.
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For further information contact:
Dr. Udo Krischke
Global Technical Manager RSTS
Tel: +49 6128 744 235
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 97,000 employees, SGS operates a network of over 2,600 offices and laboratories around the world.